The document is a presentation by Michael LeGrand from March 2015, addressing updates and interpretations of the Uniform Guidance (UG) regarding Facilities & Administrative (F&A) cost pools, as discussed at a COGR meeting. Key topics include the effective dates and implementation nuances for F&A rate calculations under the new UG, specifically referencing several regulatory clauses such as those related to indirect costs, depreciation, equipment, and rental costs. A significant focus is placed on administrative and clerical salaries, noting stricter criteria for direct charging to grants and highlighting the impact of such charges on Departmental Administration (DA) cost pools and overall F&A rates. The presentation further explores adjustments in the Utility Cost Adjustment (UCA), outlining when it takes effect, the allowable calculation methods, and the required documentation. It highlights discrepancies in interpretation between federal oversight bodies and notes evolving expectations regarding the research laboratory energy use index (REUI) and other technical factors. Remaining areas of uncertainty, such as the inclusion of specific types of research spaces and the frequency of OMB updates to relevant indices, are acknowledged.
Additionally, the document addresses other F&A pools, clarifying the treatment of shared depreciation and emphasizing recent changes such as the inclusion of postdoctoral fellows and graduate students in the categorization of library professional employees. It also touches on the rules surrounding costs for idle facilities, specifying the conditions under which such expenses may be deemed allowable. Overall, the presentation serves to inform stakeholders at institutions of higher education about compliance obligations, methodological adjustments, and policy developments pertinent to F&A rate setting under the new Uniform Guidance, while underscoring areas requiring further clarification or negotiation with federal agencies.
